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RMA Insurance Roundtable June 5, 2009
  RBC Mississauga




Facilitated by : Anthony Gagnon
Executive Consultant
jagagnon@bell.net
 Risk management more critical than ever
 ERM is in, «siloed» approaches out
 ERM implies management across business lines and
  integrating all risk categories in a strategic view
 More regulation coming, not less, with some regulation of
  systematically important shadow markets
 Risk management emphasis :
       Governance
       Liquidity
       Economic capital and procyclicality
       Product development risk and suitability
       Counterparty risk
       Reputation and moral hazard

                                                              2
   Strong and independent risk management
    will be required
   Strengthening of resiliency of critical
    payment and settlement systems
   Capital will remain key for financial
    institutions, expect higher minimum
    requirements
   Macro-prudential (systemic risk) focus for
    supervisors
                                                 3
 Establish Financial                       Implement new
  Stability Board                            principles on executive
 Extend oversight to all                    compensation
  systemically important                    Improve and
  institutions and                           harmonize accounting
  markets                                    standards
 Reform the credit                         Improve quality and
  rating agencies                            quantity of capital
  environment
 Identify and respond to
  macro-prudential risks
Learn More at : ERM Symposium April 2009, Risk and Regulation at
Financial Institutions: New Directions, Cathy Lemieux, Federal reserve of Chicago
                                                                                    4
   Systematic risk
   Eliminating supervisory gaps
   Emphasizing consumer protection (product
    suitability)
   International coordination



    Handout available at :
    http://www.ermsymposium.org/2009/pdf/handouts/2009-chicago-erm-karl.pdf

                                                                              5
 Canada is an active player in G-20 suggested reforms
 Insurancy industry regulation is under discussion at
  the Superintendant of Financial Institutions (OSFI)
 In Quebec, proposed guidelines are expected to be
  implemented by the end of 2011 covering :
       Governance
       Integrated risk management
       Interest rate risk mangement
       Liquidity risk
       Compliance
       Outsourcing

                                                         6
   Establish and operate an ERM framework
     Integrate the framework with the
      strategies, operations and business cullture
     Leadership and oversight should be a Board and
      C-suite task
     Proper ERM requires quantification of risks over
      an adequate range of potential outcomes



                                                         7
 Risk measurement must be built on reliable
     data, description of risks and their explanation
   Establish and perform an Own Risk and
    Solvency Assessment (ORSA)
             «An insurer should regularly perform its own risk and solvency assessment
           (ORSA) to provide the board and senior management with an assessment of
          the adequacy of its risk management and current, and likely future, solvency
                                                                               position.
                  The ORSA should encompass all reasonably foreseeable and relevant
                  material risks including, as a minimum, underwriting, credit, market,
                     operational and liquidity risks. The assessment should identify the
           relationship between risk management and the level and quality of financial
                                                        resources needed and available.»

                                                                                           8
   I Quantification of risks and capital
   II Governance and supervisory oversight
   III Disclosure and transparency
     Risk categories: credit, underwriting, market, liquidity
      and operational risk
     Principle of proportionality: sound and transparent
      framework in relation to nature, size and complexity
     Board accountability for framework, including
      policies, and oversight

                                                                 9
   The minimum Continuing Capital and Surplus
    Requirements (MCCSR) paper is capital
    focused.
   The paper nevertheless promotes :
     Regulatory framework areas: financial
      requirements, governance and market conduct
     An attention to risks that cannot necessarily be
      managed through financial requirements.
Reference : Federal : Canadian Vision for Life Insurer Solvency Assessment, November 2007
QC : Joint Committee (OSFI, AMF, Assuris) Framework for a New Standard Approach to setting Capital
Requirements, Draft for Comment, January 2008
                                                                                                     10
   Senior Supervisors Group
www.newyorkfed.org/newsevents/news/banking/2008/rp080306.html
   President’s Working Group on Financial
    Markets
www.treasury.gov/press/releases/hp871.htm
   Financial Stability Forum
www.fsforum.org/publications/r_0804.pdf
   ERM Symposium Chicago April
    2009, handouts
http://www.ermsymposium.org/2009/handouts.php


                                                                11
   Canada : OSFI
http://www.osfi-bsif.gc.ca/osfi/index_e.aspx?ArticleID=363
   Quebec : AMF
http://www.lautorite.qc.ca/reglementation/assurances-institutions-depot.en.html
   MCCSR Advisory Committee (MAC):
    The MAC is co-chaired by a member of the Canadian Institute of Actuaries (CIA) and a
    representative of the Office of the Superintendent of Financial Institutions (OSFI). Its
    members are senior representatives from the Canadian Life and Health Insurance
    Association (CLHIA), CIA, Assuris, the Autorité des marchés financiers (AMF), and OSFI, as
    well as representatives from large and small insurers and the reinsurance industry.
    Canadian vision for life insurer solvency assessment, November 2007
http://www.osfi-bsif.gc.ca/app/DocRepository/1/eng/guidelines/capital/guidelines/mac_e.pdf

    Solvency Advisory Committe/AMF, Framework for a New Standard Approach to setting
    Capital Requirements, Draft for Comment, January 2008
http://www.lautorite.qc.ca/userfiles/File/Consultations/solvency-committee-4.pdf



                                                                                                 12
   Proposed enhancements to the Basel II
    framework
   Range of practices and issues in economic
    capital frameworks (mars 2009)
   Amended Proposal for a DIRECTIVE OF THE
    EUROPEAN PARLIAMENT AND OF THE
    COUNCIL on the taking-up and pursuit of the
    business of Insurance and Reinsurance
    (SOLVENCY II) Brussels February 2008
                                                  13
   Credit risk transfer – developments from 2005 to
    2007, July 2008
   Credit risk transfer, March 2005
   Cross-sectoral review of group-wide
    identification and management of risk
    concentrations, Avril 2008
   Customer suitability in the retail sale of financial
    products and services, April 2008
   Financial disclosure in the banking, insurance
    and securities sectors: issues and analysis, May
    2004
The Joint Forum members are: supervisors for banks (BCBS)and insurers (IAIS);
securities regulators IOSCO
                                                                                14
   High-level principles for business continuity, August
    2006
   Initiatives by the BCBS, IAIS and IOSCO to combat
    money laundering and the financing of terrorism, June
    2003
   Operational risk transfer across financial
    sectors, August 2003
   Outsourcing in Financial Services, February 2005
   Regulatory and market differences: issues and
    observations, May 2006
   The management of liquidity risk in financial
    groups, May 2006
   Trends in risk integration and aggregation, August
    2003
                                                            15
   Issues paper on group-wide solvency assessment
    and supervision (5 mars 2009)
   Standard on enterprise risk management for
    capital adequacy and solvency purposes (October
    2008)
   Standard on the use of internal models for
    regulatory capital purposes (October 2008)
   Standards on disclosures concerning technical
    performance and risks for non-life insurers and
    reinsurers (October 2004)
   Glossary of Terms (February 2007)

                                                      16
The Canadian banking and insurance sector is dominated by a small number of
large and relatively stable players. It grew with little government intervention
until the collapse of Home Bank in the early 1920s. Ottawa then created the
Office of the Inspector General of Banks to regulate the sector with an entire
staff that could be counted on one hand. The Office of the Superintendant of
financial Institutions, known as OSFI, was created when OIGB merged with the
insurance regulator in 1987. It has since been steadily growing both its employee-
count, now standing at approximately 500, and its oversight of the industry.

OSFI continues to be more focused on the principles of sound management than
on rules. The Canadian approach is closer to the British than our southern
neighbor.




                                                                                     17
There are more than 7,000 commercial banks in the United States of which 10 to
20 could be considered to dominate the market. Financial institutions are
overseen by numerous federal and state regulators. They sometimes
overlap, leaving holes. Depending on their type, size and location, U.S. financial
institutions could be subject to a number of regulators, from the Federal Reserve
Board and, through it, the Federal Reserve Banks (which preside over about 900
state banks and roughly 5,000 bank holding companies), to the Federal Deposit
Insurance Corporation (which supervises state banks that are not members of the
Federal Reserve System), to the Comptroller of the Currency and the Office of
Thrift Supervision , etc. A Canadian Bank Executive was recently quoted as saying
their U.S. operations can have as many as 17 «inspectors» at any time.




                                                                                     18
With a career spanning more than thirty years, Anthony Gagnon offers value
added expert advice and contractual interim executive services in the areas of
finance, strategy, risk management and business unit structuring. From 2003 to
now, the majority of mandates have been in policy writing and framework
design and implementation of Basel II operational risk programs and initiatives:
general framework, business continuity, outsourcing, trust company fiduciary
risks, etc.

Typical mandates require acting on behalf of an Executive, the project sponsor, in
executing project requirements. Sponsoring Executives retain full ownership, are
involved on an on-going basis and expertise is transferred to the internal team by
the agreed delivery date.

Anthony also works on a sub-contract basis or as partner with reputable firms in
major projects requiring teams and multi-disciplinary resources.

Anthony is currently working with Desjardins General Insurance Group

                                                                                     19
20
Desjardins General
Insurance Group


 1.8 million policies and             4 subsidiaries: 2 individual insurance companies
   premium volume of                   (Desjardins General Insurance and Certas Direct)
      $1,429 million                   and 2 group insurance companies (under The
                                       Personal banner)
  Underwriting profit
   for the 15th year
                                      Operates many call centres renowned as being
        in a row                       among the most efficient in North America
                                      Client/member satisfaction:
          Assets:                      95% policy renewal rate
         $3.1 billion                 Expertise in risk and client segmentation
                                       and rates management
       Net earnings:                  Some 2,000 agents, experts and client service
       $126 million                    representatives in various client call centres in
  (Data as at December 31, 2007)       Québec and Ontario


                                                                                           21

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Regulatory discussion v2012

  • 1. RMA Insurance Roundtable June 5, 2009 RBC Mississauga Facilitated by : Anthony Gagnon Executive Consultant jagagnon@bell.net
  • 2.  Risk management more critical than ever  ERM is in, «siloed» approaches out  ERM implies management across business lines and integrating all risk categories in a strategic view  More regulation coming, not less, with some regulation of systematically important shadow markets  Risk management emphasis :  Governance  Liquidity  Economic capital and procyclicality  Product development risk and suitability  Counterparty risk  Reputation and moral hazard 2
  • 3. Strong and independent risk management will be required  Strengthening of resiliency of critical payment and settlement systems  Capital will remain key for financial institutions, expect higher minimum requirements  Macro-prudential (systemic risk) focus for supervisors 3
  • 4.  Establish Financial  Implement new Stability Board principles on executive  Extend oversight to all compensation systemically important  Improve and institutions and harmonize accounting markets standards  Reform the credit  Improve quality and rating agencies quantity of capital environment  Identify and respond to macro-prudential risks Learn More at : ERM Symposium April 2009, Risk and Regulation at Financial Institutions: New Directions, Cathy Lemieux, Federal reserve of Chicago 4
  • 5. Systematic risk  Eliminating supervisory gaps  Emphasizing consumer protection (product suitability)  International coordination Handout available at : http://www.ermsymposium.org/2009/pdf/handouts/2009-chicago-erm-karl.pdf 5
  • 6.  Canada is an active player in G-20 suggested reforms  Insurancy industry regulation is under discussion at the Superintendant of Financial Institutions (OSFI)  In Quebec, proposed guidelines are expected to be implemented by the end of 2011 covering :  Governance  Integrated risk management  Interest rate risk mangement  Liquidity risk  Compliance  Outsourcing 6
  • 7. Establish and operate an ERM framework  Integrate the framework with the strategies, operations and business cullture  Leadership and oversight should be a Board and C-suite task  Proper ERM requires quantification of risks over an adequate range of potential outcomes 7
  • 8.  Risk measurement must be built on reliable data, description of risks and their explanation  Establish and perform an Own Risk and Solvency Assessment (ORSA) «An insurer should regularly perform its own risk and solvency assessment (ORSA) to provide the board and senior management with an assessment of the adequacy of its risk management and current, and likely future, solvency position. The ORSA should encompass all reasonably foreseeable and relevant material risks including, as a minimum, underwriting, credit, market, operational and liquidity risks. The assessment should identify the relationship between risk management and the level and quality of financial resources needed and available.» 8
  • 9. I Quantification of risks and capital  II Governance and supervisory oversight  III Disclosure and transparency  Risk categories: credit, underwriting, market, liquidity and operational risk  Principle of proportionality: sound and transparent framework in relation to nature, size and complexity  Board accountability for framework, including policies, and oversight 9
  • 10. The minimum Continuing Capital and Surplus Requirements (MCCSR) paper is capital focused.  The paper nevertheless promotes :  Regulatory framework areas: financial requirements, governance and market conduct  An attention to risks that cannot necessarily be managed through financial requirements. Reference : Federal : Canadian Vision for Life Insurer Solvency Assessment, November 2007 QC : Joint Committee (OSFI, AMF, Assuris) Framework for a New Standard Approach to setting Capital Requirements, Draft for Comment, January 2008 10
  • 11. Senior Supervisors Group www.newyorkfed.org/newsevents/news/banking/2008/rp080306.html  President’s Working Group on Financial Markets www.treasury.gov/press/releases/hp871.htm  Financial Stability Forum www.fsforum.org/publications/r_0804.pdf  ERM Symposium Chicago April 2009, handouts http://www.ermsymposium.org/2009/handouts.php 11
  • 12. Canada : OSFI http://www.osfi-bsif.gc.ca/osfi/index_e.aspx?ArticleID=363  Quebec : AMF http://www.lautorite.qc.ca/reglementation/assurances-institutions-depot.en.html  MCCSR Advisory Committee (MAC): The MAC is co-chaired by a member of the Canadian Institute of Actuaries (CIA) and a representative of the Office of the Superintendent of Financial Institutions (OSFI). Its members are senior representatives from the Canadian Life and Health Insurance Association (CLHIA), CIA, Assuris, the Autorité des marchés financiers (AMF), and OSFI, as well as representatives from large and small insurers and the reinsurance industry. Canadian vision for life insurer solvency assessment, November 2007 http://www.osfi-bsif.gc.ca/app/DocRepository/1/eng/guidelines/capital/guidelines/mac_e.pdf Solvency Advisory Committe/AMF, Framework for a New Standard Approach to setting Capital Requirements, Draft for Comment, January 2008 http://www.lautorite.qc.ca/userfiles/File/Consultations/solvency-committee-4.pdf 12
  • 13. Proposed enhancements to the Basel II framework  Range of practices and issues in economic capital frameworks (mars 2009)  Amended Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the taking-up and pursuit of the business of Insurance and Reinsurance (SOLVENCY II) Brussels February 2008 13
  • 14. Credit risk transfer – developments from 2005 to 2007, July 2008  Credit risk transfer, March 2005  Cross-sectoral review of group-wide identification and management of risk concentrations, Avril 2008  Customer suitability in the retail sale of financial products and services, April 2008  Financial disclosure in the banking, insurance and securities sectors: issues and analysis, May 2004 The Joint Forum members are: supervisors for banks (BCBS)and insurers (IAIS); securities regulators IOSCO 14
  • 15. High-level principles for business continuity, August 2006  Initiatives by the BCBS, IAIS and IOSCO to combat money laundering and the financing of terrorism, June 2003  Operational risk transfer across financial sectors, August 2003  Outsourcing in Financial Services, February 2005  Regulatory and market differences: issues and observations, May 2006  The management of liquidity risk in financial groups, May 2006  Trends in risk integration and aggregation, August 2003 15
  • 16. Issues paper on group-wide solvency assessment and supervision (5 mars 2009)  Standard on enterprise risk management for capital adequacy and solvency purposes (October 2008)  Standard on the use of internal models for regulatory capital purposes (October 2008)  Standards on disclosures concerning technical performance and risks for non-life insurers and reinsurers (October 2004)  Glossary of Terms (February 2007) 16
  • 17. The Canadian banking and insurance sector is dominated by a small number of large and relatively stable players. It grew with little government intervention until the collapse of Home Bank in the early 1920s. Ottawa then created the Office of the Inspector General of Banks to regulate the sector with an entire staff that could be counted on one hand. The Office of the Superintendant of financial Institutions, known as OSFI, was created when OIGB merged with the insurance regulator in 1987. It has since been steadily growing both its employee- count, now standing at approximately 500, and its oversight of the industry. OSFI continues to be more focused on the principles of sound management than on rules. The Canadian approach is closer to the British than our southern neighbor. 17
  • 18. There are more than 7,000 commercial banks in the United States of which 10 to 20 could be considered to dominate the market. Financial institutions are overseen by numerous federal and state regulators. They sometimes overlap, leaving holes. Depending on their type, size and location, U.S. financial institutions could be subject to a number of regulators, from the Federal Reserve Board and, through it, the Federal Reserve Banks (which preside over about 900 state banks and roughly 5,000 bank holding companies), to the Federal Deposit Insurance Corporation (which supervises state banks that are not members of the Federal Reserve System), to the Comptroller of the Currency and the Office of Thrift Supervision , etc. A Canadian Bank Executive was recently quoted as saying their U.S. operations can have as many as 17 «inspectors» at any time. 18
  • 19. With a career spanning more than thirty years, Anthony Gagnon offers value added expert advice and contractual interim executive services in the areas of finance, strategy, risk management and business unit structuring. From 2003 to now, the majority of mandates have been in policy writing and framework design and implementation of Basel II operational risk programs and initiatives: general framework, business continuity, outsourcing, trust company fiduciary risks, etc. Typical mandates require acting on behalf of an Executive, the project sponsor, in executing project requirements. Sponsoring Executives retain full ownership, are involved on an on-going basis and expertise is transferred to the internal team by the agreed delivery date. Anthony also works on a sub-contract basis or as partner with reputable firms in major projects requiring teams and multi-disciplinary resources. Anthony is currently working with Desjardins General Insurance Group 19
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  • 21. Desjardins General Insurance Group 1.8 million policies and  4 subsidiaries: 2 individual insurance companies premium volume of (Desjardins General Insurance and Certas Direct) $1,429 million and 2 group insurance companies (under The Personal banner) Underwriting profit for the 15th year  Operates many call centres renowned as being in a row among the most efficient in North America  Client/member satisfaction: Assets: 95% policy renewal rate $3.1 billion  Expertise in risk and client segmentation and rates management Net earnings:  Some 2,000 agents, experts and client service $126 million representatives in various client call centres in (Data as at December 31, 2007) Québec and Ontario 21